Balha One voyage mortality ignored/not noticed by DAFF

Noticing that the voyage mortality rate was just below reportable on a short haul voyage (carrying tough northern cattle), VALE did the calcs on the IO Report for Balha One to Indonesia and sure enough, this voyage exceeded the acceptable average daily mortality rate of 0.025% (it is 0.059%). This should have triggered a "notifiable incident" investigation under ASEL but ...no.. it hasnt. Either DAFF has dropped the ball ...again...or they have carefully helped the exporters by removing this clause from the latest version of ASEL: ASEL v3.3 has point 5.6.5 j (pertaining to this issue in ASEL 3.0) with the word "deleted" alongside, albeit whilst still having maximum average daily mortality rate in the Table of notifiable criteria (Table 22). 

Regardless, the IO Summary is not adequate to explain a notifiable incident or a much higher than usual average daily mortality:
1. Given that it is likely that the ship carried young feeder cattle, there should not have been any need to treat cattle for ill-thrift - ill-thrifty cattle should not have been loaded.
2. Respiratory disease was cited as the main cause of death. BRD / pneumonia is a significant cause of death in mature cattle on long-haul voyages but these were young tough cattle on a short-haul voyage. 17/21 were apparently just ‘found dead’. Whilst early  signs of BRD are subtle, easily missed and can progress to death within 48 hours, in an outbreak, there should have been plenty of clinical cases showing the usual signs: lethargy, disinterest, standing with head lowered and neck extended, rapid shallow breathing progressing to laboured open mouth breathing, watery nasal and/or ocular discharge progressing to mucopurulent/purulent discharge with mortalities after a period of illness. BRD cases are not usually just found dead. The report mentions 28 treatments for respiratory disease but nothing further. More detail is needed - were the 21 cattle amongst the 28 treated? If so, how did they deteriorate so badly that they were "found dead" and not euthanased? So many questions and no answers in the IO Summary...and no notifiable incident logged.